ORAL TESTIMONY ON THE PROPOSED POWER PLANT RULE

BY BRUCE FERGUSON OF CATSKILL CITIZENS FOR SAFE ENERGY

http://www.catskilicitizens.org/index.cfm

JULY 29, 2014 DENVER, COLORADO

Thank you for the opportunity to testify today. I am grateful that EPA is willing to use its established regulatory authority to curb harmful emissions at a time when it is clear that Congress lacks the will to address this important issue.

I represent Catskill Citizens for Safe Energy, an all-volunteer grassroots organization with 14,000 members in New York State and around the country. My community which sits atop the Marcellus Shale, organized in 2008 in opposition to high-volume hydraulic fracturing because it was apparent that this inherently dangerous industrial process posed a threat to our drinking water, our health, and our community character. Today it is clear that fracking is not only a local issue, it's an international one, because the extraction, processing and transmission of shale gas releases so much heat-trapping methane into the atmosphere that if fracking goes unchecked it will be impossible to avoid the devastating impacts of climate change.

While I appreciate EPA's willingness to address power plant emissions, I believe the method selected to measure emissions is deeply flawed. If the rule is implemented as written, it could produce a result that is, in one important way, the exact opposite of what is intended—instead of curtailing total greenhouse gas emissions, it may actually increase them and exacerbate climate change.

The problem with the rule is twofold. First, it addresses only smokestack emissions, not all emissions produced by fossil fuels consumed by power plants. Second, it addresses only carbon dioxide, not all greenhouse gases.

It might make sense to focus solely on smokestack emissions of carbon dioxide if all fossil fuels had similar patterns of greenhouse gas emission, but that is simply not the case.

Coal releases large quantities of carbon dioxide into the atmosphere when it is burned, and these emissions would be regulated by the rule.

On the other hand natural gas, particularly shale gas that is extracted by hydraulic fracturing, releases large quantities of methane during extraction, processing and transmission. Under the proposed rule, these lifecycle emissions are not measured, and will go unregulated.Pound for pound methane traps eighty-six times more heat than carbon dioxide

when it is released into the atmosphere, and the volume of so-called "fugitive emissions" is so great that many scientists have concluded that the greenhouse gas footprint of shale gas is actually greater than that of coal over a twenty year timeframe. Robert Howarth et at reached this conclusion in 2011 1 , and it has been supported by a number of more recent studies 2 ; yet it is utterly ignored in this power plant rule.

A related problem is that EPA only considers the Global Warming Potential (GWP) of methane over the 100-year time period, which is much less that its GWP over the critical 20-year time period when we must act to avoid the dire impacts of climate change. The problem with looking at the 100-year time period instead of the 20-year time period was summed up in an article by Joe Romm aptly titled By The Time Natural Gas Has A Net Climate Benefit You'll Likely Be Dead And The Climate Ruined 2

Despite these major defects, it has been suggested that the proposed rule is a good first step, and that fugitive methane emissions can and will be addressed by another rule, at a later date. But later is likely to be too late. While EPA continues to study fugitive methane emissions, this rule, which is due to be adopted next year, explicitly encourages large-scale investment in new gas-fired power plants—plants that will be powered by shale gas.

Once these new power plants are built, the owners will understandably expect to amortize construction costs over decades. If, in a year or two, or three, EPA determines that the fugitive emissions associated with fracked gas are as detrimental as many independent scientists now say they are, and if it turns out that curtailing fugitive emissions should prove to be an intractable problem, the agency will not be in a position to reverse course and demand that newly constructed gas-fired plants be taken offline.

For this reason, fugitive methane emissions associated with shale gas must be addressed now, in the proposed rule, if it is to be an effective tool in fighting climate change. When EPA does consider the totality of harmful emissions associated with all fossil fuels, it will become apparent that replacing one fossil fuel with another makes no sense. A comprehensive assessment of lifecycle emissions from fossil fuels will lead to only one conclusion—the only responsible course of action is to rapidly develop renewable energy systems that will quickly free us from our dependence on all fossil fuels.

1. Howarth, 'R. W., R. Santoro, and A. Ingraffea. 2011. Methane and the greenhouse gas footprint of natural gas from shale formations. Climate. Change Leterst. 106:679-690. inr/ 7 '

2. By The Time Natural Gas Has A Net Climate Benefit You'll Likely Be Dead And The Climate Ruined by Joe Romm in CLIMATEPROGRESS, February 19, 2014.3. Howarth, R. W., R. Santoro, A. Ingraffea. Venting and leakage of methane from shale gas development: reply to Cathles et al. 2012. Clim. Change 113:537-549. do

Howarth, R. W., D. Shindell, R. Santoro, A. Ingraffea, N. Phillips, and A. TownsendSmall. 2012. Methane emissions from natural gas systems. Background paper prepared for the National Climate Assessment, Reference # 2011-003, Office of Science & Technology Policy Assessment, Washington, DC. Available at
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Hughes, D. 2011. Lifecycle greenhouse gas emissions from shale gas compared to coal: an analysis of two conflicting studies. Post Carbon Institute, Santa Rosa, CA. Available

Howarth, R. W., and A. Ingraffea. 2011. Should fracking stop? Yes, it is too high risk.
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